4.4.5.2   Compliance with ARARs -- Alternative 5

Alternative 5 relies on the plasma torch technology as the
primary treatment technology and waste excavation, sorting,
transportation, and storage as support technologies.  Alternative
5 would meet all federal and state ARARs.  Appendix B presents
the ARARs and criteria TBC for Alternative 5.  The ARARs and
criteria TBC for Alternative 5 are briefly discussed below.

PCBs  The plasma torch technology is capable of meeting chemical-
and action-specific ARARs for the treatment and disposal of PCBs
because it is a form of high temperature incineration.  Plasma
torch is capable of treating PCBs to a level of less than 1 ppm
in the vitrified slag treatment residual.  The vitrified slag
would need to be tested to determine the appropriate disposal
method.  It is highly unlikely that the vitrified slag would be a
RCRA characteristic hazardous waste because the vitrified
material should not leach contaminants.  Subject to verification
testing, the vitrified slag would be disposed of as a solid waste
at the 30-acre disposal facility.  The 30-acre disposal facility
would be designed, operated, and closed in accordance with state
laws and regulations governing nonhazardous solid waste disposal. 

Air Pollution  Plasma torch is a form of high temperature
incineration, and would require air pollution control
technologies in accordance with the CAA and the IAC.  In
addition, the plasma torch unit must comply with the requirements
of 40 CFR 761.70.  As with any PCB incinerator, the plasma torch
unit would need to achieve a DRE of 99.9999 percent PCBs.  This
level of destruction is possible with the plasma torch unit. 
Contaminated scrubber liquid from the air pollution control
system would be incinerated in the plasma torch unit except for
the final stream, which would be transported to a commercial
treatment and disposal facility.

Waste Treatment and Disposal  Much of the contaminated material
at the six CD sites can be treated using plasma torch.  If
transformers are found, they should be drained and flushed. 
Dielectric fluid and liquids containing greater than 500 ppm PCBs
should undergo off-site incineration.  The drained and flushed
transformer carcasses would be disposed of as solid waste along
with uncontaminated solid waste from the six sites if they
contain less than 50 ppm PCBs.  Capacitors would be drummed and
incinerated using the plasma torch.  PCB-contaminated solid waste
that cannot be treated using the plasma torch would be disposed
of at a TSCA-compliant commercial landfill or incinerator.  PCB-
contaminated material would be stored in the CTF or ISF in
preparation for treatment and disposal in accordance with 40 CFR
761.65.

Waste Excavation and Handling  ARARs associated with waste
excavation and handling would be met by Alternative 5.  Fugitive
dust and particulates would be controlled using best management
practices such as wetting the waste material with water or foam. 
Surface water runon and runoff at the six CD sites would be
controlled during excavation using berms and silt fences and by
collecting surface water runon in the excavation area using
pumps, vacuum trucks, and storage tanks.  All collected surface
water would be transferred to the CTF for treatment by the plasma
torch unit.  As part of site restoration activities, sediments
collected by the silt fences or the berms would be containerized
and transported to the CTF for treatment.  The excavation sites
would also be monitored to determine the effectiveness of dust
and surface water control systems.

Surface Water  Decontamination water and storm water runon from
the excavation sites should be collected, containerized, treated
using carbon adsorption, and discharged to a POTW or surface
water body in accordance with pretreatment standards or NPDES
limitations of the CWA.  Water from the lagoon at the Winston-
Thomas Sewage Treatment Plant site could be pumped through carbon
adsorption units and discharged to the Dillman Road POTW.

Other Requirements  Alternative 5 would also comply with other
non-ARARs including OSHA regulations governing worker health and
safety; INDOT regulations for the packaging, labeling, and
shipping of hazardous materials; and the CERCLA Off-Site Rule for
proper off-site disposal of CERCLA wastes.  All waste material
from the six CD sites handled off site must comply with the
CERCLA Off-Site Rule.